I just received a message from an IRB requesting me not to collect the
names of any specific individuals as part of a network study (text below).
The conundrum is that the community-based organization for whom I am doing
the research would like me to collect name information (so that they can
pinpoint contact redundancies). I can think of a few somewhat
time-consuming ways to comply with the IRB request, but
am wondering if there is a way to justify the collecction of names
to the IRB.
What's the current understanding within the network community - do
existing human subjects regulations disallow the collection of names when
carrying out network research? If not, what kinds of language can be used
to justify to IRBs the collection of names when conducting network
Text of IRB message:
In reviewing the interview protocol for residents, the Committee noted
that you will be asking residents to identify specific social service
agencies and specific staff members in those agencies. The federal
regulations define a human subject as a living individual about whom an
investigator (whether professional or student) conducting research obtains
(1) data through intervention or interaction with the individual, or (2)
identifiable private information [45 CFR 46.102(f)].
To avoid any named staff members being considered a "subject", as
described above, the Committee requests that you instruct residents not to
mention any social service staff member by name.